FPA Submits Comments on EPA’s Proposed Reconsideration and Withdrawal of EPA’s 2009 Endangerment Finding that “Greenhouse Gases (GHG)” Endanger Public Health and the Environment

The Flexible Packaging Association (FPA) appreciates this opportunity to submit comments on the EPA’s Proposed Reconsideration and Withdrawal of EPA’s 2009 Endangerment Finding that “Greenhouse Gases (GHG)” endanger public health and the environment. In the August 1, 2025 Notice of Proposed Rulemaking (NPRM or Notice), the Endangerment Finding is accompanied by the Agency’s proposal to reconsider and rescind all mobile source GHG standards based on the agency’s belief that it lacks the Clean Air Act (CAA) statutory authority and record basis that was required to create and maintain “this novel and transformative regulatory program.” 90 FR 35289/3. FPA is very concerned that the joinder of the proposed withdrawal of EPA’s GHG Endangerment Finding with the proposed withdrawal of EPA’s GHG Mobile Source Standards is likely to mislead the public, which may not understand that the Endangerment Finding is the predicate for all of EPA’s stationary source GHG regulations as well as the agency’s CAA mobile source program.